20151065 Ver 1_Email_20130927

Homewood, Sue
From:
Darling, Richard <[e-mail]>
Sent:
Friday, September 27, 2013 1:59 PM
To:
Homewood, Sue
Cc:
'Williams,: Andrew E SAW' (Andrew. E.Williams2@usace. army. m il); Alex Rosser; Behrens,
Paul; Allen, Larry
Subject:
FW: Pleasant Ridge 401 permitting
Sue:
Thanks very much for the discussion on 09/10/2013 regarding DWR Secondary & Cumulative Impacts expectations for
the proposed 401 certification of the PTIA NW Taxiway and Pleasant Ridge airport development project - please
correct/update/revise as necessary. Based on our conversation, I understand the following:
• As part of the 401 certification -process, DWR is required to determine that a project "does not result in
cumulative impacts, based upon past or reasonably anticipated future impacts, that cause or will cause a
violation of downstream water quality standards."
• The only guidance specific to this determination requirement is the "Cumulative Impacts and the 401 Water
Quality Certification and Isolated Wetland Permit Programs" internal policy document dated April 10, 2004
(Version 2.1)
• This guidance was developed primarily for NCDOT projects, but is applicable to PTIA
• DWR will rely on the Corps approach to the Individual 404 Permit - preliminarily, NW Taxiway (only) will be
permit application - to more precisely determine the requirement for analysis of 401 Cumulative Impacts
• PTAA (applicant) is responsible for providing DWR with acceptable documentation that no further degradation
of downstream waters (Brush Creek, 303(d) -listed and Nutrient Sensitive) will occur from future development
precipitated by the project
• Based on anticipated project impacts (Individual Permit), this documentation could be qualitative (policy item
1.13) or quantitative (policy item 'I.C)
• In either case (above), the burden is on the applicant (PTAA) to satisfy DWR that potential future development
spurred by the -project is not likely to further degrade downstream water quality
I further understand that, until refinements in project and 404 specifics are completed, DWR cannot more precisely
determine the secondary and cumulative impact analysis expectations. I will endeavor to keep you informed of major
progress in relevant project planning and design and the 404/401 application status in order to refine the cumulative
impacts analysis requirements appropriately. Again, please add to and modify my understanding as appropriate and I
look forward to working with you to complete the water quality certification process as efficiently as possible. Thanks,
as always, for your time and efforts, Sue.
Richard
Richard B. Darling I Environmental Manager I Michael Baker Engineering
8000 Regency Pkwy., Suite 600 1 Cary, NC 27518 1 919.463.5488 (office) 1 919.481.5740 (direct)
rdarlinoC)mbakercorp.com I www.mbakercorp.com